ARE GOODS SUBJECT TO SPECIALIZED INSPECTION ELIGIBLE FOR STORAGE AT ALTERNATIVE LOCATIONS? – NEW GUIDANCE FROM THE GENERAL DEPARTMENT OF CUSTOMS
On August 26, 2026, the General Department of Customs issued Official Letter No. 20974/CHQ-GSQL responding to Mitsubishi Elevator Vietnam Co., Ltd. regarding procedures for bringing goods to alternative storage locations during specialized inspection/customs clearance pending periods.
1. General Principles
- Goods subject to specialized inspection must be stored at border gates until customs clearance is granted.
- However, goods may be moved to alternative locations for specialized inspection or storage under the following circumstances:
- Current laws permit moving goods to alternative locations to carry out specialized inspections; or
- The goods owner requests to bring the goods back for storage.
- Crucial Condition: The storage location must meet customs supervision requirements, and the goods shall remain under customs supervision until official clearance is completed.
2. Bringing Goods for Storage Upon Designated Requests of Specialized Inspection Authorities
- The declarant shall submit a request to transfer goods to an inspection location according to the criteria specified in Form No. 18, Appendix II of Circular No. 38/2015/TT-BTC (as amended and supplemented).
- Enclosed with the Registration Certificate for Specialized Inspection bearing the certification of the specialized inspection authority, to be submitted to the customs office.
3. Key Takeaways & Notable Points
- No Immediate Submission Required: Enterprises are not required to submit documents proving that the storage location satisfies customs supervision conditions at the exact time of requesting storage relocation.
- Subsequent Customs Verification: Within a maximum period of 30 days from the date of confirming the relocation of the first shipment for storage, customs authorities will inspect the storage facility to verify compliance with supervision conditions.
- Enterprises are responsible for retaining and presenting the following upon customs request:
- Valid documents proving the right to use the storage facility;
- Documents proving that the facility meets customs supervision requirements;
- Relevant dossiers serving the inspection process.
IMPORTANT NOTICE FOR IMPORT-EXPORT ENTERPRISES
The temporary exemption from submitting proof of supervision conditions at the time of application does not mean enterprises are permanently exempted from these requirements.
Recommendation: Enterprises should proactively review their intended storage locations, prepare complete dossiers regarding land/facility usage rights, and ensure compliance with supervision conditions prior to the arrival of the first shipment to avoid failing subsequent customs audits within the 30-day window.
Legal Basis
The legal grounds cited by the General Department of Customs include: Article 35 of the Law on Customs; Article 33 of Decree No. 08/2015/NĐ-CP (amended and supplemented by Decree No. 167/2025/NĐ-CP); Clauses 3 and 5, Article 32 of Circular No. 38/2015/TT-BTC (amended and supplemented by Circular No. 39/2018/TT-BTC and Circular No. 121/2025/TT-BTC).
ATTACHED DOCUMENTS / IMAGES (Click on the image to enlarge):
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